https://www.taxtmi.com/caselaws?id=796326 Subcontract payments could not be benchmarked under the other method because the Common Schedule of Rates did not reliably show the application of basic rates and premiums to the relevant works, and the claimed internal comparable was not established. Benchmarking was therefore required under the Transactional Net Margin Method. Under that method, comparables selected for build, maintain and transfer functions were not functionally aligned with an operation, maintenance and transfer arrangement. The arm's-length analysis must be redone using functionally appropriate operation, maintenance and transfer comparables after providing an opportunity of hearing. en-us Thu, 30 Jul 2026 00:00:00 +0530 Tue, 04 Aug 2026 08:39:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796326 Subcontract payments could not be benchmarked under the other method because the Common Schedule of Rates did not reliably show the application of basic rates and premiums to the relevant works, and the claimed internal comparable was not established. Benchmarking was therefore required under the Transactional Net Margin Method. Under that method, comparables selected for build, maintain and transfer functions were not functionally aligned with an operation, maintenance and transfer arrangement. The arm's-length analysis must be redone using functionally appropriate operation, maintenance and transfer comparables after providing an opportunity of hearing. Case-Laws Income Tax Thu, 30 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796326